LETTER | Time, info needed for public consultation on price control of medicines

LETTER | While Malaysians have been increasingly concerned over the rising prices of essential items, the issue of prices for medicines appears to have escaped the notice of the public.

Public consultation on the effect of price controls on medicines is currently underway. I would like to draw the public’s attention to this and urge the public to participate in this process by providing their feedback and concerns on this issue.

The public consultation period started on Nov 29, 2021, and will close on Dec 6 2021, a period that is too short for such an important topic, in my opinion.

The public consultation focuses on the preliminary findings of a cost-benefit assessment (CBA) of the implementation of medicine price controls proposed by the Ministry of Health (MOH).

The CBA is coordinated by the Malaysian Productivity Corporation (MPC), a statutory body under the Ministry of International Trade and Industry (Miti), with the collaboration of several government bodies, economists, and private industry groups such as the Pharmaceutical Association of Malaysia (Phama), the Association of Private Hospitals of Malaysia (APHM), and curiously, the Pharmaceutical Research & Manufacturers of America (PhRMA).

This collaboration was governed by a steering committee chaired by the deputy secretary-general of Miti and a technical committee chaired by the deputy director-general of MPC and an industry representative from Pama. The study was conducted by an unnamed third party consultant.

A single public consultation document summarising the preliminary findings of the CBA has been put online for consideration. A public webinar was also organised by the MPC on Dec 1, 2021, where a reading of the consultation document was held, followed by a short Q&A session.

Public consultation needs time, transparency and information

The preliminary findings of the CBA suggest that the implementation of price controls for medicines will have an adverse effect on the private healthcare sector and on the Malaysian economy as a whole.

The preliminary findings also suggest that the negative impact will outweigh the positive benefits of price controls for medicines.

To arrive at this conclusion, the CBA included an impressive range of potential adverse impacts, including reduced profit margins for the pharmaceutical industry and private hospitals, large-scale closures of GP clinics and private hospitals, and a reduction in medical tourism, and compared it against what appears to be a single benefit i.e. patients’ savings.

It is unclear from the public consultation document if other potential benefits were considered, such as lives saved, improved health outcomes, increased productivity as a result of improved health, improved quality of life, savings in public health expenditure, or even increased spending in other economic sectors as a result of reduced out-of-pocket healthcare expenditure.

The public consultation document also lacks technical information on some of the assumptions and the data on which the findings are based on.

I believe that a public consultation requires ample time, transparency, and information to be provided to the public before any conclusions can be made.

I strongly urge the MPC, MITI, and the CBA steering and technical committees to make public the full technical report and data of the CBA, along with a comprehensive description of the methodology and assumptions used.

This is to allow for the findings to be reviewed and validated in order to reassure the public.

As the subject matter has a tremendous impact on the health of the public and the accessibility of healthcare, I would also recommend that all members of the technical committee of the CBA provide full disclosures and conflict-of-interest statements to the public.

Lastly, I would once again urge the MPC to extend the period of the public consultation and encourage members of the public to participate in this public consultation process and to raise concerns and comments.

The website for the public consultation can be found here.

MARK CHEONG WING LOONG is a lecturer at the School of Pharmacy, Monash University Malaysia.

The views expressed here are those of the author/contributor and do not necessarily represent the views of Malaysiakini.